SCOTLAND's failure to reform its defamation laws may impose a chill on free speech across the rest of the UK, according to leading campaigners.

Holyrood ministers say they have no plans to replicate rules being introduced to protect ­writers, scientists and publishers from libel actions in England and Wales and bring legislation up to date with the digital age.

Last week the Faculty of ­Advocates warned that Scottish courts, with Scotland's weaker protections for freedom of expression, could be used to pursue people elsewhere, including in England.

The London-based Libel Reform Campaign fears Scotland now provides a back door for those who wish to apply pressure south of the border and elsewhere.

Robert Sharp, of freedom of expression group English PEN and the Libel Reform Campaign, said: "The worrying gap between protections in England and Wales and Scotland is allowing a chilling loophole to exist and this is especially concerning after Scots voted to stay in the United Kingdom."

The internet, and in particular social media, means that defamatory statements published in England, for example, could almost certainly be deemed to have been published in Scotland. So somebody who believes they have been defamed online - in, for example, the electronic version of a newspaper, story can now choose where to sue.

This "forum shopping" is already understood to have led to some actions heading north since English and Welsh laws changed. Campaigners fear that the risk of libel tourism to Edinburgh could mean cautious publishers in England are chilled into self-censorship by the threat of a ­Scottish lawsuit.

The Westminster law - much of which came into effect earlier this year - came after London itself became a world capital for libel tourism. However, the England and Wales law introduced a concept of "substantial harm" designed to limit the exposure of publishers to libel actions - and provided a new public interest defence for whistleblowers.

The Scottish Government did not adopt the legislation into Scots Law, which is different and does not include the English concepts of libel by written word and slander by spoken word. A spokeswoman said reform was being kept "under review".

Mr Sharp added: "We have every respect for Scots law and understand that it is not the same. But as long as the loophole exists, the chill exists. As long as we have the UK, we can say that if somebody has a reputation in England that can be tarnished, they have a reputation in Scotland too. This is a real constitutional issue and we hope Scotland will adopt a defamation act quickly."

Scottish PEN, a sister organisation to English PEN, stressed it was worried about the impact Scotland's defamation laws will have on the development of blogging and other new journalism as the country's government requires more scrutiny under increasing devolution.